The National Court has confirmed that the company to which the producer of the actor, director and producer of the ‘Torrente’ saga belongs, santiago safemust pay the Treasury almost one million euros by way of liquidation for corporation tax for the period 2010-2011.
In a judgment of the Contentious-Administrative Chamber of the National Court, advanced by The Newspaper of Spain and collected by Europa Pressthe court rejects the appeal filed by AE William Holding SL –Business group in which the production company was integrated ‘Friends’— against the resolution of the Central Economic-Administrative Court of February 14, 2019 that set the amount at 827,183.39 euros, considering that it is “adjusted to Law”.
This company appealed in 2019 before the National Court the settlement agreement issued by the Tax Assistance and Services Unit of the Central Delegation of Large Taxpayers of the Tax Agency (AEAT), in relation to Corporation Tax. All after the producer’s companies had gone through a complex series of business movements that included takeovers of some companies over others.
The court explains that in this case, Segura’s defense questioned whether or not article 90.3 of the Consolidated Text of the Corporate Tax Law (TRLIS) limited the compensation of negative tax bases at the acquiring entity’s headquarters and whether the Administration was obliged to follow the criteria established in final court rulings.
The Chamber clarifies that this article 90.3 “what it intends is to avoid the decomposition due to the double use of losses that can occur both if the company with negative tax bases is the absorbed entity or if it is the absorbing company”.